Magna Code of Conduct and Ethics

MAGNA INTERNATIONAL | CODE OF CONDUCT AND ETHICS

Glossary

Bribe:

Giving or offering to give something of value to someone for his or

her personal benefit in order to obtain business or some other advantage. This

includes the payment of small sums – sometimes called “facilitation payments”

or “grease payments” – to low-level government officials to obtain routine

services to which the person would otherwise be entitled.

Compliance:

Following the letter and spirit of the law, this Code, and all

Magna policies.

Good faith:

With an honest and sincere intention.

Government official:

An officer or employee of a government, department

or agency, any public international agency, or any person acting in any official

capacity on behalf of the government, department or public international agency,

as well as any other person deemed to be a government official by Magna’s

procedures.

Inside information:

Information not known by investors or the public that,

if it was known, would significantly change their view regarding the value of a

company, or its stock or bonds. Examples include a significant acquisition or

merger, changes in senior management, significant litigation or labour disputes.

Kickback:

A form of bribe in which a sum of money already paid or due to be

paid is returned as a personal reward for fostering a business arrangement.

Lobbying:

Communications with government officials at any level of

government, including individuals elected to public office, staff and employees

of government agencies, intended to promote, oppose or otherwise influence

decision-making.

Relatives or close friends:

Includes a spouse, domestic partner, child,

parent, grandparent, grandchild, sibling, aunt, uncle, niece, nephew, in-law relative,

step/adoptive/foster relationships, an individual related to you who resides in your

home, and a friend with whom you socialize outside of work.

Thing of value:

Can take the form, among many other things, of money, gifts,

donations to charity, excessive travel and entertainment expenses, educational

expenses, promises of future employment, or shares of a company.

Third Party:

A person, organization or business operating external to Magna.